East Devon Catchment Partnership East Devon Rural Diffuse Pollution

East Devon Catchment Partnership

East Devon Rural Diffuse Pollution Project

Final Report

Purpose of report

To review the methods, results and findings of the East Devon Rural Diffuse Pollution Project, May 2015 – March 2016.

This project was commissioned by the East Devon Catchment Partnership through an Environment Agency Catchment Partnership Action Fund (CPAF) grant.

The project delivery and reporting was overseen by Devon Wildlife Trust.

Report compiled by Chantal Brown (Chantal Brown Consulting), with contributions and additions from other members of the East Devon Catchment Partnership involved in the project.

All photographs © Environment Agency.

[email protected] 0777 8700 539

Contents

Summary 1. Introduction 2. Method 3. Weather conditions 4. Results 4.1 Response from farmers to initial offer of advice 4.2 The land holdings visited and their characteristics 4.3 Issues, risks and recommendations discussed during farm visits 4.4 Awareness of farmers to pollution responsibilities and mitigation measures 4.5 Demonstrations of good practice 4.6 Identification of barriers to the uptake of environmental management and schemes 4.7 Details of workshop contributions 4.8 Response from farmers at end of second visit, and observations of impact of farm advice on farming practice 4.9 EA findings on sites visited for audit visits following advice 4.10 Results by land holding after all site visits, and analysis against risk

5. Discussion and recommendations 5.1 Awareness of maize pollution issues, responsibilities and alternatives among landowners 5.2 Advisory provision on maize and alternatives 5.3 Enforcement of the regulatory framework 5.4 Effectiveness of the project’s approach, and recommendations for follow-up

6. Annexes to report 6.1 Land holdings in agri-environment schemes 6.2 Breakdown of land holdings n the project by catchment 6.3 Overview of soils by catchment 6.4 Mapping of land holdings influenced 6.5 Example letters to landowners 6.6 Factsheets developed for the project 6.7 Project budget

Executive Summary

Runoff from maize can cause serious diffuse pollution and contribute to localised flooding. Due to the scale of maize growing and potential impacts it is a priority issue for the East Devon Catchment Partnership. The East Devon Rural Diffuse Pollution Project provided consultancy advice to farmers in East Devon to reduce impacts from maize growing in 2015-16 and subsequent years. The project gives a ‘snapshot’ of the severity of the issue in east Devon.

Methods The project identified 50 high risk farms across the East Devon catchments of the Otter, Axe and Clyst. Risk was identified by the Environment Agency (EA) based on numbers of dairy cows / cattle, land used for AD plants and history of pollution. Of the 50 farms, 44 were maize growers and 30 of these voluntarily engaged with the project. Farmers received an initial letter and phone call, followed by two visits (one farm office-based, one field-based). They were also sent two advisory letters and a series of farm maps identifying risk areas, runoff routes identified by LIDAR, mapping of specific recommendations and detailing soil types and their associated risk based on soil type, and a visual assessment evaluation. A series of maize ‘fact sheets’ developed by the East Devon Catchment Partnership were also given to farmers. Presentations were given about the project at four local Catchment Sensitive Farming events. This reached 71 farmers. Only a small proportion (7) of these farmers were from the initial list of 50 high risk farms.

Results from advisory visits Advice was provided by Chantal Brown Consulting (CBC) on focused areas within farm holdings. The total area receiving detailed advice was 715 hectares. 77% of farms visited were dairy farms, with the majority of those remaining growing maize for anaerobic digestors. 50% of the farmers visited had received funding from the Catchment Sensitive Farming scheme and 23% were in Entry Level Stewardship. Maize harvest was delayed on all farms due to an unseasonally cold and wet August (240% of the long term average monthly rainfall fell in East Devon). Advice could not be given on choice of maize varieties as the project was delivered in the two months prior to harvest when crops had been already planted. It was found that 69% of the maize crops being grown were not ‘very early’ harvesting varieties (Maize Growers Association ripening score of 10 or more). Most farmers were growing early varieties (scores of 8 or 9). The field assessment during site visits found that 27 farms were growing maize in a field that was categorized as high or very high risk, when scored for size, slope, soil type, environmental features and compaction. Risks identified in the field were run-off, pollution, compaction, erosion, waterlogging, and mud on roads. A detailed analysis was also carried out using soil maps provided by Cranfield University that determined risks based on Soil Association types approximately found on holdings. This data showed that:  less than 19% of the land used for maize production was (naturally) freely drained and therefore likely to be suitable for harvesting during the Autumn without damaging the soil  over 93% of the land used was at high risk of run-off  nearly 60% of land used for maize production was at risk of erosion and gullying on slopes  over 50% of maize land had a high risk of slurry pollution The awareness from farmers about the financial risks of failing to meet new cross compliance requirements on dealing with soil erosion, and the legislative implications of causing a pollution incident from soil runoff was very low.

Almost half of the farms visited had made efforts at crop establishment stage to plan for an early harvest, for example, by using early varieties or by growing under plastic, and 69% had made efforts at crop establishment stage to reduce run–off by drilling across the slope or provision of buffer strips. All except one farm carried out some post-harvest work on some of their maize land, and 59% of farms had effective mitigation measures when surveyed at the start of winter. A common mitigation measure was cultivating strips or establishing a following crop. There were only three farms that had examples of good practice with a relatively early maize harvest, and where the following crop had been established in dry conditions resulting in soil that was not compacted.

Results from field survey audits EA carried out field survey audits during heavy rainfall between mid-January and early March 2016 on 27 farms. EA staff found that:  63% of farms (19 in total) had ineffective mitigation measures causing soil runoff which was found to be entering watercourses  19% of farms (5 in total) had a serious impact on watercourses (defined by the EA as Category 2 water incident)  run-off was found on all of the 27 farms audited but not all of this was found to be entering watercourses at the time of the visit  pollution caused from slurry was entering watercourses on 30% of farms (8 in total) The main cause of the widespread runoff found was due to the late maize harvest. This meant that cultivation of maize stubble and establishment of grass and following crops was not carried out in suitable conditions. Much of East Devon has land that is at high risk of runoff, and so late harvest inevitably results in runoff problems. Although serious runoff problems were found, the EA have taken an advisory and warning approach in the first instance with farmers who have voluntarily engaged, albeit within a formal regulatory framework. Further enforcement action will be considered should serious runoff problems continue.

Discussion and recommendations This project has provided a ‘snapshot’ of the widespread and serious runoff problem from farms in east Devon, resulting from a combination of bad weather and growing maize on high risk land with a low level of farmer awareness of legal responsibilities and techniques to prevent runoff and pollution. The project has gone some way to provide constructive and practical advice to the farmers involved; however, significant effort is required in the future to address the issues identified. Recommendations from the project include:  Farming representatives and advisory organisations need to raise farmer awareness in East Devon regarding best practice in growing maize  Advisory provision for maize growers in East Devon should be adequately resourced  Existing land use advisors should undertake in-depth training on maize and pollution issues  The farming sector itself should actively provide advice about the pollution risks from maize growing and the mitigation required  The EA should consider more effective ways to communicate and engage with farmers on high risk farms  Targeted follow-up visits should be carried out in 2016 on all farms advised during the project This project has successfully engaged with hard-to-reach landowners. It should be considered as an effective model to tackle diffuse pollution from agriculture in high risk areas. 5

1. Introduction The East Devon Rural Diffuse Pollution Project was a one-year initiative aimed at reducing the diffuse pollution arising from rural land use, in particular the growing of maize, in the East Devon river catchments of Clyst, Axe and Otter. It was funded through the Environment Agency Catchment Partnership Action Fund (CPAF). This supports Catchment Partnerships to tackle issues which are preventing achievement of Water Framework Directive objectives which have been identified by the partnership.

The East Devon Catchment Partnership

The East Devon Catchment Partnership covers the catchments of the river Exe, Clyst, Culm, Creedy, Sid, Otter, Lim and Axe river systems. The aim of the Partnership is to bring together a wide range of stakeholders, and engage local communities, to secure better outcomes for the East Devon river catchments and their associated environments. The primary driver for the Catchment Based Approach is the need for the UK to meet its water quality obligations under the Water Framework Directive. It is also driven by Defra’s Catchment Based Approach Policy Framework (May 2013) and Guide to Collaborative Catchment Management (August 2013). Water quality improvement and delivery of Water Framework Directive objectives are the principle focus for the East Devon Catchment Partnership. In addition the Partnership seeks to deliver a range of wider benefits through an integrated management approach, including flood mitigation, biodiversity enhancement, community engagement and re-creation. The Partnership is hosted jointly by Devon Wildlife Trust and the Westcountry Rivers Trust, supported by the Environment Agency. Other partners include Blackdowns AONB, Clinton Devon Estates, East Devon AONB, Exmoor National Park, FWAG South West, Natural England, South West Water, Westcountry Rivers Trust, and Exe Estuary Partnership.

Project overview

Rural diffuse pollution has been identified as a major issue by the East Devon Catchment Partnership. The Catchment Partnership Environmental Services Evidence Review demonstrates that agricultural practice is the major contributing factor to diffuse rural pollution, and that production of maize is a high risk land-use which is contributing to this, leading to large levels of soil runoff and sediment (and other pollutants) entering water bodies.

Due the huge complexity associated with positive soil management (e.g. risk factors, land-use) the partnership decided to focus on soil management advice in relation to maize crops. Sediment loads are a major pressure on water bodies in the area. Runoff from maize remains a major problem in East Devon (including Clyst and Culm, Sid, Axe and Otter Operational Catchments) and now potentially increasing due to anaerobic digestion plants using maize as a feedstock. The area includes high risk sandy soils of East Devon and a significant area of heavy soils (hence the need for specific and focussed soils advice).

This project was commissioned as a contribution to reducing diffuse pollution from maize growing in East Devon catchments, through targeting specialised advice to high risk farms. Advice was provided to landowners to help them manage their soils under maize production in a more sustainable and economically viable way, to secure future reductions in sediment loads and thus contributing to a reduction in diffuse pollution levels in the specified water bodies.

A large part of the East Devon catchment area is a target area for Catchment Sensitive Farming (CSF) and farmers have received advice in relation to maize and soil management in the past. However, despite all the good advice and capital grant funding received by farmers through CSF, rivers data indicates that diffuse pollution is still a persistent and growing problem. 6

This project aimed to deliver an innovative approach to existing advisory provision, with a strong focus on delivering positive and constructive advice to landowners, followed up with an audit visit from the Environment Agency as the regulatory authority for pollution.

2. Method 2.1 Preparation and farmer contact A list of 50 high risk farms was provided by the East Devon Catchment Partnership to the contractor (Chantal Brown Consulting, CBC). Farmers were identified by the Environment Agency as potentially ‘high risk’ based on history of pollution, high numbers of cattle, and growing blocks of maize for AD plants. CBC wrote to all 50 farmers informing them of the project and inviting them to take up the offer of free advice and participate in the project. The letter was jointly written by CBC and the Partnership, and the Catchment Based Approach logo was used. The letter informed farmers that the Environment Agency (EA) would be carrying out a wet weather survey the following spring. Sample letters are included in section 6.4 of the annex to this report. All 50 farmers were called as a follow-up to the letter and offered a free advisory visit from CBC. A minimum of three attempts were made to contact each farmer, including leaving messages; after which it was deemed that no response indicated a lack of support for the project. Communications with all landowners were recorded on a confidential database.

2.2 Advisory farm visits by consultant Initial visits were carried out by two advisors from CBC, Chantal Brown and Stewart Sinclair, between 19th August 2015 and 9th October 2015. Initial visits were farm office-based exercises and involved looking at farm soil maps and discussing the project and the farmers’ plan for post- harvest field management. The ‘typical’ format of the initial visits is outlined below. Information Provision  Background to the project. Detailing the partners, the work carried out to the date, and looking at the Water Framework Directive map for the farm area to highlight where waterbodies are currently failing to meet environmental objectives  New cross compliance rules and potential penalties, with a focus on Good Agricultural and Environmental Condition (GAEC) 5  Discussions on the EA walk over- what they will be looking for and what the risks are if a pollution problem is identified including liabilities with legislation Information Collation  Farming practice (area, maize ground, cropping rotation/stock numbers)  Maize varieties grown  Previous run-off issues/ post-harvest issues (mud on road/ flooding etc)  Post-harvest plan  Agronomist and contractor details  History of engagement with Catchment Sensitive Farming / Countryside Stewardship/EA Following up from initial visit, farms received a follow up letter (approximately 2 pages) containing:  Details recorded about the farm and current practice  New RPA rules  Risks if a pollution incident is found/reported  Potential risks and recommendations on their farm  Key messages about planning  Grants advice and contact details  The CABA factsheets 7

 Early Harvesting varieties list Post-harvest field visits were arranged with farmers. All second visits were carried out between 29th October and 11th December 2015.  Using maps, CBC identified a minimum of three fields per farm that had been maize harvested and that posed a higher pollution risk.  During the visit, soil pits were dug in each field, and any run-off or site-specific areas of concern were mapped alongside recommendations. Soil structure and compaction was discussed and the cultivations and/or field management were recorded. Throughout the project, photos were collated alongside data from each farm. Following up from the field visit, farmers received annotated risk and recommendation maps, a LIDAR predicted run-off map (although LIDAR coverage was not available for two of the farms), an update on details of funding and advice available through CSF and an advisory letter (average length 4 pages including photos and the risk table of the 3+ fields). An example letter follows in Annex 7.5. All farmers received this information in December 2015. In early January 2016, following approval from Cranfield University to share their data, each farm also received a soil map for their holding, using data obtained under licence from Cranfield University (NSRI). The maps showed the approximate soil types occurring on the holding based on the 1:250,000 national soil map, with the legend giving summary information about the soil texture and winter wetness. In the covering note, each farm was given information about the character of the soils found on their holding (as per table 3.3 below). Farmers were also directed to Cranfield’s online “The Soils Guide” to access detailed descriptions of each soil type found on their holding. In mid-January 2016 all farmers were contacted by phone to ensure everyone had received all the information provided, and to provide any follow up support that was requested. Advisory letters and maps were re-sent to the four farmers who reported that they had not received these the first time.

2.3 Environment Agency audit visits EA carried out audit visits during wet weather on 27 of the farms engaged within the project during January-March 2016 to assess the scale of soil runoff from maize fields entering watercourses. Where serious soil runoff was found causing pollution and where organic pollution was also found, the EA carried out regulatory visits. This regulatory work is continuing during 2016. A ‘formal’ advisory and warning approach was taken in the first instance by the EA with farmers engaged in the project. All landowners involved in the project received follow-up letters from EA with an indication of the outcome of audit visits.

3. Weather Conditions The weather during the project period had an influence on harvest dates, post-harvest management (in some cases) and run-off. The weather conditions in August led to a delayed harvest, with 240% more rainfall than average in the Otter, Sid, Axe, Lim catchment. However, rainfall during the autumn and winter was only above normal during January and February, but not exceptional.

Table 3.1: Monthly rainfall per catchment displayed in relation to long term averages Data from the monthly Environment Agency ‘Water Situation Reports’. Values are the percentage of the 1961-1990 long term average rainfall each month for the stated hydrological area. Data supplied Produced using final and provisional NCIC (National Climate Information Centre) data (Source: Met Office © Crown Copyright). Crown copyright. All rights reserved. Environment Agency, 100026380, 2015. Otter, Sid, Axe, Exe Catchment Lim Catchment Month Status Long Term Status Long Term Average Average July 2015 190% Above normal 183% Above normal August 2015 240% Exceptionally high 180% Notably high September 2015 79% Normal 86% Normal October 2015 87% Normal 66% Below Normal November 2015 94% Normal 113% Normal December 2015 99% Normal 106% Normal January 2016 142% Above Normal 143% Notably high February 2016 118% Normal 128% Normal

The following map shows that rainfall was above normal but not exceptional (Dec-Feb) compared to the north of the country.

4. Results

4.1 Response from farmers to initial offer of advice Of the 50 farm details provided at the beginning of the project, thirty farms engaged with the project and accepted farm visits. Of the 20 farms who did not engage, the following reasons were given:  6 did not grow any maize  11 did not want visits for the following reasons: o They were too busy at that time o They considered they are doing everything they are asked to do o They have had lots of visits in the past from different groups all offering advice  CDC was unable to make contact with 3 farms, despite numerous attempts. Farmers who engaged with the project were keen to hear of new Good Agricultural and Environmental Condition (GAEC) rules and the risks of being found to pollute. There was an element of concern from some farmers about the EA visiting their farm, typically this was a concern from dairy farmers, in particular those farming on heavy ground. The farm visits were largely being organized at a very busy time of year, and many of the farmers were resistant about engaging with a new project during harvest and silage cutting times.

4.2 The land holdings visited and their characteristics  Farm visits completed: 30  Total hectarage of holdings visited: 4499.34 ha  Total hectarage of maize grown in 2015 on holdings visited: 715.30 ha  Total hectarage of maize advised on with specific field recommendations: 478.30ha 77% of the farms visited were dairy farms, with the remaining being farms growing maize for anaerobic digestion. On average, 18% of farm areas were cropped for maize in 2015, although some farms had put 40-50% of their land to maize. Table 4.2 details the type of maize grown by each farm visited. Using Maize Growers’ Association (MGA) definitions, all farms were growing early varieties of maize (MGA scores 8+). 12 out of 26 (46%) farmers grew very early maize varieties (MGA score 10+). Many farmers are still being advised and are selecting to grow varieties that are not the earliest available. The Catchment Sensitive Farming Initiative ran five events in the project area in 2010-2011 with the aim of promoting early varieties. There were 78 attendees at these events, only one of which was from the target list of fifty farmers provided for this project. There have been following events more recently that have related to post-harvest management of maize and alternative crops to maize. Eight of the thirty farms visited (27%) reported they grow maize in two consecutive years. These farmers received advice about crop rotations. 75% of the farmers cropping maize without a break crop were also farmers that were not growing very early varieties. Maps of the land holdings that received advice are given in the annex under 6.3.

Table 4.1: Land holdings visited

Area of Extra maize Proportion of Holding ground Farm Farming type grown (ha) holding down to size (ha) rented (ha) 2015 maize 2015 (%)

Farm 1 Dairy 153.19 17.31 11.30 Farm 2 Dairy 155.18 62.40 40.21 Farm 3 Dairy 149.09 10.72 7.19 Farm 4 Dairy 47.85 105 12.92 27.00 Anaerobic 226.62 243 18.82 Farm 5 Digester (AD) 8.30 Farm 6 Dairy 101.48 12.63 12.45 Farm 7 Dairy 135.19 404 9.64 7.13 Farm 8 Dairy 61.51 28 4.44 7.22 Farm 9 Dairy 43.94 36 21.91 49.86 Farm 10 AD and Dairy 165.06 15.61 9.46 Farm 11 AD 378.61 35.65 9.42 Farm 12 Dairy 162.74 39.86 24.49 Farm 13 Dairy 147.05 20.64 14.04 Farm 14 Dairy 157.80 49 18.68 11.84 Farm 15 Dairy 68.43 3.44 5.03 Farm 16 Dairy 138.16 36.37 26.32 Farm 17 Dairy 45.61 100 6.31 13.83 Farm 18 Dairy 71.74 21 12.02 16.75 Farm 19 Dairy 45.23 33 13.75 30.40 Farm 20 Beef and Sheep 105.62 14.67 13.89 Farm 21 Dairy 77.55 11.58 14.93 Farm 22 Dairy 110.87 14.02 12.65 Farm 23 Dairy 62.84 55 No maize harvested in 2015 Farm 24 Dairy 268.73 27.71 10.31 Farm 25 AD and beef 174.75 405 31.29 17.91 Farm 26 AD 632.25 21.87 3.46 Farm 27 Dairy 89.16 28 13.05 14.64 Farm 28 Dairy 229.63 127.16 55.38 Farm 29 AD 141.66 66.07 46.64 Farm 30 Dairy 151.80 14.76 9.72

Table 4.2: Varieties of maize grown on each holding Varieties in red are considered early harvesting varieties by the MGA; those in green are from MGA 10 up and considered ‘very’ early varieties. Farmers with unsuitable Farm Variety of maize grown rotations Farm 1 P8200, ISANTO and P8057 Maize to maize Farm 2 MGA 8s & MGA 10s Farm 3 Ambition (MGA 9) & Kontender (MGA 8) Farm 4 Kontender (MGA 8) Maize to maize Farm 5 Severus (MGA 8) Farm 6 MGA 9 & 10 Farm 7 MGA 9s & 10s Farm 8 Fieldstar (MGA 8) Farm 9 Glory (MGA 10) Farm 10 Could not recall Farm 11 Glory (MGA 10), Marco (MGA 5), P7892 (early) Farm 12 No data available Ambition (MGA 9) on light ground & Crescendo (MGA Maize to maize Farm 13 8) on heavy ground Farm 14 Ambition (MGA 9) Farm 15 MGA 9s Farm 16 Early harvesting (MGA 10+) Farm 17 MGA 8s & 9s Farm 18 Crescendo (MGA 8) Maize to maize Farm 19 MGA 10s Farm 20 Acumen (MGA 9) Farm 21 MGA 9s Farm 22 Justina (MGA 8) Maize to maize Farm 23 No maize in ground 2015 Farm 24 Early (MGA 10) Farm 25 Glory (MGA 10) Farm 26 Glory (MGA 10) Farm 27 Ramirez (MGA 10) Maize to maize Farm 28 Augustus (MGA 10) Maize to maize Farm 29 Glory (MGA 10) and Atrium (under plastic) (MGA 7) Maize to maize Farm 30 No data available

Table 4.3: Soil associations in maize on the holdings visited, and associated risks

Area (ha) in Map maize in 2015 Winter Run-off Maize Harvesting Gulley Erosion Slurry Soil Association Soil Group Texture Group Comments Symbol on holdings Wetness Risk Suitability Risk Pollution Risk visited*

431 WORCESTER 18.60 Pelosols wet clayey High Low suitability Low risk High High risk of compaction. 541b BROMSGROVE 25.92 Brown earths freely loamy High Suitable Erosion on slopes Low Unstable fine sand and silt. drained 541B BEARSTED 2 42.34 Brown earths freely loamy High Suitable Erosion on slopes Low Unstable fine sand and silt. drained 541w Newnham 20.24 Brown earths freely loamy High Suitable Erosion on slopes Low Unstable fine sand and silt. drained 551a BRIDGNORTH 1.70 Brown sand freely sandy High Suitable Erosion on slopes Low Unstable fine sand and silt. drained 571l CHARITY 1 53.51 Brown earths freely loamy High Suitable Erosion on slopes Low Unstable fine sand and silt. drained 572f WHIMPLE 3 269.02 Stagnogleyic slightly wet loamy over clay High Moderate suitability Erosion on slopes High High risk of compaction & erosion risk. 572i CURTISDEN 24.51 Stagnogleyic slightly wet loamy over clay High Moderate suitability Erosion on slopes High High risk of compaction & erosion risk. 582a BATCOMBE 146.52 Stagnogleyic slightly wet loamy over clay High Moderate suitability Low risk Low High risk of compaction. Found on the clay cap hills. 711b BROCKHURST 1 11.82 Stagnogley wet loamy over clay High Low suitability Low risk High High risk of compaction. 711f WICKHAM 2 14.07 Stagnogley wet loamy over clay High Low suitability Low risk High High risk of compaction. 712b DENCHWORTH 5.28 Stagnogley wet clayey High Low suitability Low risk High High risk of compaction. 714a DUNKESWELL 21.72 Stagnogley wet loamy over clay High Low suitability Low risk Low High risk of compaction. Found on the clay cap hills. 811b CONWAY 0.20 Alluvial gley wet loamy and Low Moderate suitability Low risk Moderate High risk of compaction. clayey 813b FLADBURY 1 18.82 Alluvial gley wet clayey Low Moderate suitability Low risk Moderate High risk of compaction. 871b HENSE 25.85 Groundwater wet loamy over Low Not suitable Low risk High Very wet, rushes, woodland. gley sand * NB slight discrepancy between total hectarage of all soil types in maize and total hectarage of all maize grown owing to ‘unsurveyed’ areas of National Soil Survey. ** NB Soil types were used from the national soil map at 1:250,000 (i.e. at a coarse resolution). These were extrapolated to the farm scale to only give approximations of the soils types present. Each Soil Association will have a range of differing Soil Series when examined at the field scale.

Table 4.3 above details the risks associated with the soil associations where maize was grown on the holdings visited. Risks for different soil associations were assessed to determine winter wetness; run-off risk; maize harvesting suitability; gulley erosion risk; and slurry pollution risk. This was based on soil texture (0 to 80cm), soil water regime and suitability to cultivation and cropping published in the Soil Survey of England and Wales Bulletin no. 14 – Soils and Their Use in South West England. Inherently wet soils over clay were classed more at risk of runoff than freely draining soils. These wetter soils were also classed as being less suitable for maize because they tend to be wet during October in the high rainfall areas of the South West and therefore vulnerable to compaction during harvesting. Soils with a high sand and silt content were classed more at risk to gulley soil erosion due to their instability. The wetter soils on slopes were classed at high risk of causing slurry runoff and pollution.

4.3 Issues, risks and recommendations discussed during first farm visit The following issues were discussed on the first advisory visit:  Soil maps: risks associated with different soil types and options for managing different soil types  Compaction and deep cultivation: looking for compaction at different depths and options for alleviating compaction at different times of year, using different machinery  Manures: storage and timing and method of spreading and incorporation  Drainage: finding out if drains are in place, if they are managed, what depth they are at, moling. (There was a low level of awareness about drain management and few people had experience of moling. Many farmers were not routinely managing drains, with more of an ad hoc approach when a problem occurs)  Over-sowing and cover cropping benefits and risks  Risks associated with harvest: plan/options for optimum conditions, plan/options for worst case scenario  Planning for maize in the future: field options within the farm and points to consider  Mitigation: buffer strips, moving gateways, contours, rolling, checking field drains, installing silt traps, cultivations, diverting water, not trafficking, drilling winter crop earlier, harvesting earlier, increasing width of cultivated strips, increasing width of buffer strips, establishing grass corners, establishing grass buffers, removing compaction, post harvest management.

4.4 Awareness of farmers to pollution responsibilities and mitigation measures During advisory visits, many farmers claimed that they did not know about pollution law in relation to soil runoff, and knowledge relating to their pollution responsibilities was low. The EA’s application of pollution control to farming was also poorly understood by farmers. Awareness was low to the risk of fines and criminal proceedings aside from Basic Payment Scheme (BPS) regulations. However, within this, awareness of the cross-compliance / GAEC rules relating dealing with soil erosion and post-harvest management of late harvested crops was also very low. Where farmers were aware of mitigation measures against pollution from maize growing, these were often poorly understood. Mitigation measures were often stated as buffer strips or trying to follow with a grass re-seed, rather than detailing the full suite of planning and management options needed to ensure maize is grown responsibly. Likewise with grass re-seeds, farmers often seemed to think this was the best option, despite evidence that run-off can be made worse by a late drilled grass re-seed after maize. The message about rough cultivating rather than forcing the next crop on was new to many farmers, who stated they had thought the advice was simply to not leave soil bare over winter. However, in a general sense, most farmers knew that growing maize on steep fields was a high risk activity, and those that continued to choose these fields stated that they only did so as they didn’t have any alternative fields.

4.5 Demonstrations of good practice Three farms (6, 24 and 26) had successfully avoided run-off last winter on several high risk fields by harvesting the maize early and establishing the next crop in dry conditions after removing compaction. Some run-off was found from these holdings, but there were also cases of good practice. The key with all three examples of good practice was the earlier harvest. All three farmers had all their work done before the rain came, so the following crop was established by the end of October when it started to rain, whereas many farmers were still waiting another month to harvest maize. There were five total number of different categories of existing best practice identified during visits: grass established by deep over harrowed land to remove surface compaction , drainage repairs, following crop drilled early, rough cultivated strips & blocks of land, and subsoiling.

4.6 Identification of barriers to the uptake of environmental management and schemes 9 of the 30 farms had Entry Level Stewardship Agreements and 15 had been in receipt of Catchment Sensitive Farming funding. Analysis of the uptake of agri-environment schemes can be found in section 6.1 of the annex to this report. Many of the dairy farmers visited had looked at either Entry Level Stewardship or Middle Tier Countryside Stewardship; however, they found that their farming system was not sufficient to reach the points requirements for these schemes. Many farmers felt entering into an environmental management scheme would be at an overall cost to their farm business. There was a very high level of awareness and uptake of the Catchment Sensitive Farming Scheme across the East Devon Catchment. Farmers spoke very highly of the CSF officers, and many had said they had phoned their local advisor on receipt of the letter, to see how this project worked with the CSF. Many of the dairy farmers had been successful in receiving grants for yard works that they felt had had positive effect in helping them reduce the volume of slurry they produced. Several farmers had been successful in receiving grants over a number of years, and the farm infrastructure was in a good state as a result. There were however still some potential run –off issues on farm from management within the field, and some inappropriate siting of farmyard manure.

4.7 Details of workshops attended The consultant attended the following workshops and events with materials on the East Devon Diffuse Pollution project, and about maize growing:  “Making the most of grassland”, Dalwood, Axminster, Thursday 1st October, 2015  "Management and Feeding of Forage Crops" event, Wilmington, 3rd November 2015  "Soil Health and Biology" event, Broadclyst, 11th November 2015  “Farm Infrastructure” event, Talaton, 19th November 2015 The total number of attendees at the above four events was 71, only seven of whom were from the project’s target list of 50 farmers.

4.8 Response from farmers at end of second visit, and observations of intentions and impact of farm advice on farming practice All farms that engaged through the initial visit agreed to another visit post-harvest, indicating positive interaction with the project. EA staff joined the CBC advisor on some of these visits, purely in an advisory and training capacity. Due to the conditions many farmers were in a situation that was not what they had hoped or planned for (see weather report under 2.0). In further discussion about the harvest and post- harvest plans the farmer had detailed during CBC’s first visit, it was clear that many issues were due to the delayed harvest and the persistent rain that followed. Farmers all recognized the issues that were being identified and were equally as concerned about them and the potential risk of fines later in the season through EA or Rural Payments Agency (RPA) inspections. Significant time was spent by the advisor discussing what options were available to the farmer in response to the current situation on a field by field basis, giving a range of options for if the field conditions allowed cultivations, or if not, how to remedy in spring when it dries up, and importantly, what measures could have been in place to avoid the results found in 2015-16. In all cases, where run-off and/or erosion was identified or found to be a high risk of occurring if there was much more rainfall, farmers were in agreement that if rainfall eased and the land dried up, they would be happy to break up compaction in critical areas and rough cultivate to break run-off lines. Due to the heavy soils in much of the project area, and the rainfall through November and December that was above normal but not exceptional (See section 3 for rainfall data), many farmers that were unable to harvest the crop off early and follow with prompt cultivations did not get an opportunity to carry out the necessary remedial works, and therefore the run off problem has been exacerbated. Some of the farmers who had not carried out cultivations were reluctant to loosen soil due to the land being more difficult to work in the spring, due to it being softer and not suitable for slurry spreading or

travelling, and therefore delaying spring drilling. In these cases, the fields were often not adequately drained for growing maize. There were several examples of farms that had attempted to implement the advice from the first visit, but not executed it correctly to reduce all run off. Issues identified around roughly cultivating strips were that they were not deep enough, wide enough, didn’t take out headland compaction, and left loose soil next to a watercourse that could then wash into the brook. After both advisory visits had been carried out, a risk score was given to the fields advised on for each farm, based on data and observations in the field. Details of these are given in tables 4.7, 4.8 and 4.9 below, combined with the results from the EA audit visits.

4.9 EA findings on sites visited for audit following advisory visits Following two advisory visits from the consultant, 27 of the 30 farms were visited by EA during rainfall events. All 27 farms visited were found to have some run off, detailed in the following table.

Table 4.6 Severity of runoff found on 27 farms during EA audit visits Number of % of total Incident farms Category 2 water incident, 19% 5 (serious) Category 3 water incident, 44% 12 (minor) Category 4 water incident, 37% 10 (no impact)

 19% of the 27 farms (5 in total) had serious impact on watercourses (Category 2) This is where there are significant concentrations of suspended solids in the receiving watercourse (>500 mg/l) and where the watercourse is a sensitive habitat for example, where it is used by salmon and trout for spawning or where the watercourse is a designated habitat such as a SSSI or Special Area of Conservation  A further 44% of farms (12 in total) had minor impact on watercourses (Category 3)  Slurry and silage pollution was found to be occurring on 30% of farms (8 in total)  Runoff causing localised flooding with water on roads was found at 37% of farms (10 in total)

A category 2 water pollution incident is considered serious enough for the EA to take formal action which could involve prosecution. For the purposes of this project, and because farmers had voluntarily engaged with the project, it was decided to take a ‘formal’ advisory and warning approach where appropriate in the first instance with farmers. However should the problem persist then further enforcement action would be considered which may involve prosecution and / or referral to the RPA. Each incident is dealt with on a case by case basis and the enforcement approach decided by the EA on circumstance due to the weather, bad practice, attitude, history and foreseeability. The EA also decided to take a more formal approach with one farmer who did not engage cooperatively with the project, where serious soil runoff was found by sampling water quality during wet weather.

4.10 Results by land holding after all site visits, and analysis against risk data Table 4.7 below provides a snapshot of the issues relating to growing maize, mitigation measures and pollution incidence on the farms in the project. The scale of the issues range from Category 2 to Category 4 incidence and are distributed across the catchment.  46% of farmers had made efforts at crop establishment stage to plan for an early harvest, for example, by using very early varieties or growing under plastic  20 of the 29 growers (69%) had made efforts at crop establishment stage to reduce run–off, through contour drilling or provision of buffer strips  No in-field grass strips were identified on the farms, most grass buffer strips were used to buffer water courses on lower parts of fields, and many were also compacted.  All except one farm had carried out some post harvest work on some of their maize land, however there were some heavier fields that were left as stubble due to the soil wetness and the late harvest.  17 out of 29 (59%) farms had effective mitigation measures when surveyed at the start of winter and the measure and field capability was preventing run-off from occurring at the time of field assessment in mid October – mid December 2015. However, the EA auditing process, carried out after heavy rainfall between mid January and early March 2016, highlighted that 17 out of 27 (63%) farms had ineffective measures and runoff with an impact on watercourses. Of those, 19% had a serious impact on watercourses. The following table illustrates the mitigating measures that were in place prior to the first visit, during the second visit, and with photos from the EA wet weather surveys in Jan-March and details on the effectiveness of the mitigation measures through the winter.

Table 4.7 Pollution mitigation measures taken per farm, and results from advisory and audit visits NB: Photos from one maize field at Farm 18 were not from a field CBC visited or advised on

Pre Mitigation effective Mitigation effective at EA Farm Post harvest harvest at CBC field visit? Photo 1 (Jan-Mar 2016) Photo 2 (Jan-Mar 2016) field visit? ID measures measures (Oct-Dec 2015) (Jan-March 2016)

Some ‘very Cat 3 incident, (minor) early’ No. Run-off evident. varieties, Strips not deep Runoff found entering into Cultivated 1 plastic, enough. Buffer local watercourse. strips buffers needed to be Evidence of soil erosion > 1 against increased. ha in the field. river

Cat 4 water incident (no Yes. Strips partially impact). Some ‘very Grass re- effective, although Runoff found but impact on early’ seed. the headland to the watercourse not varieties, Cultivated gateway had not investigated. 2 select strips. been cultivated that gently would likely cause Soil erosion restricted to Rough sloping run-off later in the headland. fields only cultivated season. Compaction evident, flat rolled. Runoff from stored manures also found.

Cat 2 water incident No. Work carried out (serious) One field in the wet, Muddy runoff found causing grass re- compaction evident, localised flooding and 3 None seed, rest poor soil structure, serious sediment discharge uncultivated run-off. Serious run- to the local watercourse stubble off from uncultivated stubble. Soil erosion > 1ha.

Cat 3 incident, (minor) Harvested early, Runoff found entering into compaction local watercourse. Plastic, Yes. Strips and dealt with, contour rough cultivated field Soil erosion restricted to 4 wheat drilling, effective when visited compacted headland. Soil established, buffer strips after heavy rain. sediment deposit on and rough flowing over buffer strip. cultivated No runoff apparent in main strips. cultivated field. Cat 2 water incident Some crops (serious) drilled but Muddy runoff found causing stopped due No. Perched water widespread flooding on to wet Buffer table over clay highways and serious 5 conditions. strips subsoil, crops poorly sediment discharge to the Lower field established. local watercourse. cultivated to act as a Soil erosion > 1ha. Runoff buffer overwhelmed cultivated buffer area.

Cat 3 incident, (minor) Yes. Compaction Some ‘very Runoff found entering into had been removed early’ local watercourse from and crop established varieties, Wheat headlands and gateway in dry. Surveyed after contour established area. 6 a week of heavy drilling, relatively rain., small amount Soil erosion greater than buffer early of run off breaching 1ha found where ditch strips, the buffer strip. Field culvert had been blocked bunds, drain needed repair. with debris causing water to

flow over the field. Some early Wheat after varieties, maize with a 7 Yes Not visited Contour rough drilling seedbed. Cat 4 water incident (no impact). Runoff found but impact on Maize Yes. No run –off watercourse not 8 None stubble (no evident (flat, low risk investigated. action) field, rutted).. Large area of wheel ruts found on field causing runoff following slurry spreading.

Cat 3 incident, (minor)

Grass Yes. No run-off Runoff found entering into All ‘very reseed, where shakerator local watercourse. early’ 9 cultivated had ripped strips, varieties, Soil erosion > 1ha. strips across and no run-off from buffers. Cultivated strips slope grass re-seed. overwhelmed by runoff

Cat 3 incident, (minor) Runoff observed entering No. Cultivated strips into local watercourse and Grass re- Contour breached. Grass re- onto highway. seed, 10 drilling (1 seed effective, cultivated Soil erosion > 1ha. field) compaction dealt strips Cultivated strips had helped with effectively. to reduce runoff but these were over-whelmed.

Cat 4 (no impact) Yes. No run-off evident due to the Some compacted topography, but pan headlands in with signs of Some ‘very Wheat evident, water some waterlogging with early’ 11 established logging, localised minor runoff. Main field varieties, early. compaction from with cereal crop following bunds trafficking post maize had no sign of runoff. harvest in standing Impact on watercourse not water. investigated.

Wheat and Cat 3 incident, (minor) grass Runoff observed flowing established, onto highway (impassible) compaction and into ditch / removed Yes. No run-off watercourses from maize Buffer (sub-soiled evident. Wheat and 12 stubble. strips twice). One grass well field was established (early). Soil erosion > 1ha. very late- Slurry spread with some harvested runoff. Possible Cat 2 and left as incident. Flat fields stubble reduced impact of runoff

Cat 4 (no impact) Yes. Compaction in sprayer wheelings, Minor runoff observed on but overall good soil compacted headlands. structure and flat low Sediment runoff flowing Barley and risk fields, with grass over field margin. Poor 13 Buffer strip grass and barley well crop growth in main field established. established. but with no runoff observed. Drainage issue in Impact on watercourse not large field to be dealt investigated. with in spring.

Cat 3 incident, (minor) Runoff observed entering Grass into local watercourse. established, Plastic, No. Serious run off Soil erosion > 1ha. 14 some fields buffer strips from grass re-seed. left as maize Soil had poor structure in stubble. the grass reseed following maize causing widespread surface saturation and runoff.

Cat 4 (no impact) Standing water in field with Buffer Grass re- Yes. Grass 15 some runoff out of gateway. strips seed established early. Low risk field.

Cat 3 incident, (minor) No. Run-off from Grass re- Runoff found entering into All ‘very stubble where strips seeds, local watercourse. 16 early’ had been ripped. cultivated varieties Grass re-seed did Soil erosion > 1ha. strips not have run off. Runoff had overwhelmed cultivated strips.

Cat 4 (no impact) Contour Runoff found. Yes. No run-off and drilling, wheat was well Soil erosion >1ha. 17 slopes Winter wheat established in mid down to Impact on watercourse not October. grass investigated.

Cat 2 water incident (serious) Muddy runoff found causing flooding on highway. Cultivated areas overwhelmed by runoff. Grass re- seeds Yes. Cultivated Serious runoff from nearby Contour established headlands effective compacted maize stubble 18 drilling, early, and grass (on same holding that had buffer strips cultivated established well. not received specific advice headlands or had implemented measures). Soil erosion > 1ha. Flooded road was impassable. Nearby watercourse found to be completely full with sediment.

Cat 3 incident, (minor) Runoff found entering into local watercourse. All very Grass re- No. Run-off from 19 early Soil erosion > 1ha. seeds grass re-seeds. varieties Compacted soil in grass reseed following maize.

Cat 4 (no impact) Runoff found flowing along No. Run off from headland and onto nearby stubble and from Silt pond Grass/wheat road and flowing over 20 wheat – grass ? managed established adjacent grass field. reseed drilled in the wet. Impact on watercourse not investigated.

Cat 3 incident, (minor) Runoff found entering into local watercourse. Grass re- Soil erosion > 1ha. Buffer seed, wheat No. Gullying and run 21 strips established off in grass re-seed. Most erosion was due to early. river overtopping banks upstream and flowing across the flood plain. Compacted wet areas found with wheel ruts.

Cat 4 (no impact) Runoff found flowing onto Grass/wheat nearby road. Contour established, No. Some run-off 22 drilling, some rough leaving compacted plastic cultivation stubbles. Impact on watercourse not carried out investigated.

No maize in No Maize in 23 ground N/a Not visited 2015 2015 Cat 3 incident, (minor) Runoff found entering into Yes. No run-off local pond / watercourse. evident, crops well All ‘early’ established. Some Soil erosion > 1ha. Wheat 24 varieties, compaction in lower established Second maize field buffers part of grass re-seed investigated. No runoff field, due to 3 day found in cereal crop delay in drilling. following maize. Early drilled with relatively good soil structure. All ‘early’ Wheat/grass Yes. Crops well 25 Not visited varieties established established. Cat 4 (no impact) Some compacted headlands in with signs of Yes. Compaction some waterlogging with All ‘early’ had been removed Wheat/grass minor runoff. Main field 26 varieties, and crop established established with cereal crop following plastic. in dry. Surveyed after maize had no sign of runoff heavy rain apart from tramlines. Impact on watercourse not

investigated.

Cat 3 incident, (minor) Runoff found entering into No. Run-off from local pond / watercourse. bare stubble evident, All ‘early’ compounded impact Soil erosion > 1ha. Buffer strips, varieties, by muck heap in field 27 grass re- contour and compacted seed drilling wheelings towards Second maize field stream. No run-off investigated. Minor runoff from grass re-seed. found in grass crop following maize.

Cat 2 water incident Yes. No run-off (serious) evident although All ‘early’ fields very high risk. Muddy runoff found causing Rough varieties, Cultivated strips flooding on highways and cultivated contour were effective and serious sediment discharge 28 stubble, sub- drilling, compaction had to the local watercourse. soiled, cover plastic, been removed and crop Soil erosion > 1ha with buffers surface left rough erosion gulley. Runoff with the cover crop overwhelmed cultivated broadcast on. strips. Cat 2 water incident (serious) Muddy runoff found flowing Wheat No. Severe run off Some out of gateway, along farm established, from stubble and ‘early’ track with serious sediment 29 Some wheat fields, varieties, discharge to the cultivated cultivated strips not plastic watercourse. Soil erosion > strips effective 1ha.

Runoff overwhelmed cultivated strips.

Cat 4 (no impact) Runoff found mainly along compacted headlands. Yes, wheat Wheat and Soil erosion >1 ha. Farm established None grass 30 effectively to prevent Appeared that following established run-off. crop had failed. Impact on watercourse not investigated.

Table 4.8: Farm risk and field risk using visual assessment data and Environment Agency wet weather survey data.

Water pollution Highest risk Risk identified Average incident Farmer Scale of field Scale of correctly at field visit farm risk category (EA ID farm risk surveyed out Field risk where run -off with out of 25 assessment of 25 impact was identified data)

Farm 1 15 High 19 High 3 Yes Farm 2 17 High 18 High 4

Farm 3 20 Very high 23 Very high 2 Yes Farm 4 12 Moderate 18 High 3 Yes Farm 5 20 Very high 20 Very high 2 Yes Farm 6 18 High 21 Very high 3 Yes Farm 7 15 High 18 High not surveyed

Farm 8 13 Moderate 13 Moderate 4

Farm 9 14 Moderate 15 High 3 Yes Farm 10 19 High 22 Very high 3 Yes Farm 11 16 High 19 High 4

Farm 12 15 High 21 Very high 3 (could be 2) Yes Farm 13 14 Moderate 18 High 4

Farm 14 17 High 19 High 3 Yes Farm 15 13 Moderate 13 Moderate 4

Farm 16 17 High 20 Very high 3 Yes Farm 17 20 Very high 22 Very high 4

Yes (but should Farm 18 16 High 17 High 2 have been very high risk identified) Farm 19 20 Very high 22 Very high 3 Yes Farm 20 16 High 20 Very high 4

Farm 21 21 Very high 22 Very high 3 Yes Farm 22 21 Very high 22 Very high 4

No Farm 23 No maize No maize No maize not surveyed maize Farm 24 16 High 19 High 3 Yes Farm 25 18 High 20 Very high not surveyed

Farm 26 15 High 17 High 4

Farm 27 22 Very high 23 Very high 3 Yes Farm 28 20 Very high 21 Very high 2 Yes Farm 29 21 Very high 22 Very high 2 Yes Farm 30 14 Moderate 15 High 4

EA incident category: 4 = runoff with no impact, 3 = minor water impact, 2= serious water impact

Table 4.8 above combines the findings from all site visits with analysis of the risk assessed for each field. The field assessment scored fields based on their size, slope, soil type, environmental features and compaction. Risk was assessed as follows: Farm X Size (1-5) Slope (1-5) Soil Type Environmental Compaction Total Risk (1-5) features (1-5) (1-5) (Range: 0- 25) Field xxxx Large = 5 Very Steep Heavy River at Compact 25/25 = 5 Clay= 5 bottom of field sub-soil, = 5 plough pan and surface compaction= 5

Using the data collected in the field to assign a risk score to each maize field, we can identify that the farmers within the project were rightly assigned to the project as high risk farmers. Two of the 29 farmers growing maize had their highest risk field scored as of moderate risk, but their farms produced a Cat 4 incident during the Environment Agency follow up surveys. The remaining 27 farms had fields that were high or very high risk and all produced either a Category 2, 3 or 4 run-off incident. Although 30 farms is a relatively small sample size, the field assessments carried out are potentially an effective method for identifying risk of causing a pollution incident. Table 4.9 below details 16 farms that carried out some mitigation measures, and still had run-off problems. 14 of the 16 run-off incidents from these target farms had an impact on the watercourse and the list includes all the Category 2 Incidents identified. This evaluation provides an opportunity to focus on the core of the problem farms within the East Devon catchments in the study, assess the advice that was given through the project and gain understanding of uptake of advice in 2015 and planned uptake in 2016 in light of EA findings and the loss of topsoil and soil structure after the late harvest of 2015.

Table 4.9 Pollution from farms that undertook some mitigation measures during 2015 Took advice/had some Category Incident (EA Farmer ID mitigation measures in place assessment data) Farm 1 Yes 3 Farm 3 No 3 Farm 4 Yes 3 Farm 5 Yes 2 Farm 9 Yes 3 Farm 10 Yes 3 Farm 12 Yes 3 (could be 2) Farm 16 Yes 3 Farm 18 Yes 2 Farm 19 Yes 3 Farm 20 Yes 4 Farm 21 Yes 3 Farm 22 Yes 4 Farm 27 Yes 3 Farm 28 Yes 2 Farm 29 Yes 2

Table 4.10 below highlights the key risks per catchment on the land down to maize on each holding for the duration of this project. When looking widely across the whole catchment, there are important themes that demonstrate the scale of the issue in this locale:  Less than 19% of the land used for maize production is freely drained  Over 93% of the land used for maize production has been assessed as at high risk of run-off, based on soil type.  Less than 19% of the land used for maize production is considered suitable for maize harvesting, based on soil type.  Nearly 60% of land used for maize production is at risk of erosion and gullying on slopes, based on soil type.  Over 50% of maize land has a high risk of slurry pollution, based on soil type. Refer to the maps in 6.3 alongside table 4.10.

Table 4.10: Overview of soils & risk by catchment based on soil type Clyst & Culm Lim & Axe Sid & Otter TOTALS Sum of % of maize Sum of Area % of maize Sum of Area % of maize Total area (ha) of % of maize grown Risk factor Risk Area (ha) of grown in (ha) of maize grown in (ha) of maize grown in maize grown on on all holdings of Soil Category maize catchment grown on catchment grown on catchment holdings visited, visited, in all Association grown on on holdings holdings holdings in all catchments catchments on this holdings visited visited visited on this risk risk category of soil visited category of soil Winter Wet 10.42 6.2 92.87 23.26 19.61 22.45 122.9 18.77 Wetness slightly wet 115.41 68.64 237.83 59.56 57.85 66.23 411.1 62.78 freely 42.31 25.17 68.62 17.18 9.89 11.32 120.82 18.45 drained

Run-off Risk High 163.88 97.47 358.91 89.88 87.15 99.77 609.94 93.15 Low 4.26 2.53 40.41 10.12 0.2 0.23 44.87 6.85

Maize Not suitable 25.85 6.47 25.85 3.95 Harvesting Low Suitability 6.16 3.66 52.46 13.14 19.41 22.22 78.02 11.91 suitability Moderate 119.67 71.17 252.39 63.21 58.06 66.46 430.12 65.69 suitability Suitable 42.31 25.17 68.62 17.18 9.89 11.32 120.82 18.45

Gulley Erosion on 157.72 93.8 164.38 41.16 67.74 77.55 389.84 59.53 Erosion Risk slopes Low risk 10.42 6.2 234.95 58.84 19.61 22.45 264.98 40.47

Slurry High 121.57 72.3 145.62 36.47 77.26 88.45 344.45 52.60 Pollution Moderate 4.26 2.53 14.56 3.65 0.2 0.23 19.02 2.90 Risk Low 42.31 25.17 239.14 59.89 9.89 11.32 291.34 44.49

5 Discussion and recommendations The East Devon Diffuse Pollution Project has provided a ‘snapshot’ of pollution arising from maize growing on farms in east Devon, resulting from a combination of unsuitable farming practices on high risk land with a low level of farmer awareness of methods and legal responsibilities to prevent pollution. The EA audit visits have been crucial to define the scale of the issue, and to confirm that the 30 farms visited were correctly identified as high risk farms for pollution from maize growing. The results of the audit visits have shown significant runoff and pollution in the 2015-16 season. All 27 farms showed run-off issues, with 17 out of 27 farms causing Category 2 or 3 incidents. The project has provided constructive and practical advice to the farmers involved; however, significant effort is required in the future to address the issues identified. This section discusses aspects of the project in more detail, and makes recommendations for further actions.

5.1 Awareness of maize pollution issues, responsibilities and alternatives among landowners The results of this project have demonstrated a widespread and serious issue of runoff and pollution risks from maize growing in East Devon, despite a long period of focused effort in East Devon from the Catchment Sensitive Farming initiative, former projects and events run by partner organisations such as FWAG SW, Westcountry Rivers Trust and the Maize Growers Association. However, it should be noted that all the initiatives listed above rely on voluntary participation from interested farmers, not necessarily those farmers that are at high risk of causing pollution. The runoff problem is particularly acute during poor weather years where farmers are growing maize in high risk situations. Dairy farmers have been under difficult economic circumstances due to low milk prices, and this may contribute to farmers taking unacceptable risks, for example by growing larger blocks of maize and taking chances with the weather and conditions in order to maximize yields and financial returns. Whilst risk cannot be totally removed when growing maize, blaming poor weather for problems is not acceptable if the consequences of runoff cause serious pollution and flooding where best practice has not been implemented. The project has highlighted the following issues in achieving more sustainable maize management:  All farmers should be undertaking measures at crop planning and establishment stage to bring harvest forward. More farmers need to be aware of which maize varieties are the most early maturing. Members of the Maize Growers Association who have access to the MGA variety list were very much in the minority of the farms visited.  Over-simplified messages about pollution mitigation can contribute to run-off. There were many misunderstandings among farmers about what is needed in their particular circumstances. In a number of instances, mitigation measures were put in place on farm but they were not effective in preventing serious runoff. Late drilled grass re-seeds contributed to the run-off problem as much as compacted stubbles in many cases. It is most likely that the bulk of cultivation measures were carried out too late in the year.  Farms that prevented serious run-off, with no run-off even after periods of heavy rainfall, such as Farm 24, had harvested early and followed with crops that had been established in dry conditions.  Farmers should be encouraged to increase their understanding of soils on the farm, the risks of runoff arising, and the implications for their current farm practices. Further guidance for land use advisors as well as farmers about soil capability with practical case study examples would be beneficial to increase understanding in best practice. Ultimately, in order to avoid pollution, maize should only be planted in appropriate locations. Farmers need the knowledge and skills to grow maize responsibly and/or consider alternatives (such as hybrid rye) where high risk land is not appropriate for growing maize.

Recommendation 1 Farming representatives and advisory organisations need to raise farmer awareness in East Devon regarding best practice in growing maize, and about the conditions in which maize growing would not be suitable as it would be too high risk. This information needs to be tailored to local circumstances, including an emphasis on soils.

5.2 Advisory provision on maize and alternatives Through its targeted approach, this project has demonstrated that that a voluntary approach to landowner takeup of advice in East Devon in recent years has had limited effectiveness in securing advisory provision on the high risk farms where arguably it is most needed. It is likely that only significant investment in advice and information for maize growers, through both the industry and statutory providers of advice, coupled with effective enforcement of regulation, will have a meaningful impact on the issue. This project indicates that targeted advice is more effective than a voluntary approach. Successful engagement with high risk farmers has been enabled by the EA involvement in the project. Without this, it is unlikely thirty farmers would have engaged voluntarily. This demonstrates the crucial role of the regulatory aspect of pollution control in securing farmer action. In addition, without EA’s auditing work, the efficacy of the mitigation measures and the severity of the run-off would not have been captured, and the scale of the issue would not have been evaluated.

Recommendations 2 Advisory provision for maize growers in East Devon should be adequately resourced. East Devon Catchment Partnership could play a leading role in promoting this. Targeted advice is preferable to a voluntary approach. 3 Existing land use advisors should undertake in-depth training on maize and pollution issues, to make sure that the sector is making the best use of its existing advisory resource to help manage the problem. East Devon Catchment Partnership could play a useful role in commissioning training programmes. 4 The farming sector itself should actively provide advice about the pollution risks from maize growing and the mitigation required, through organisations such as NFU and Country Landowners’ Association and Maize Growers Association, seed merchants, contractors, agronomists, farm accountants and business planners.

5.3 Enforcement of the regulatory framework Positive advice and encouragement of farmers to actively reduce run-off is clearly important. However, in order to secure positive action by farmers, a regulatory system is required with the powers and resources to ensure enforcement. This approach does not necessary have to involve penalties from the EA or RPA in the first instance to engage with farmers (a formal advisory and warning approach was used by the EA in this project). However the threat of penalties, where appropriate, is needed in the background and these should be used to deal with persistent problems. Farmers need to know that if they do not take responsibility to avoid pollution from their operations, then the risk of prosecution is very real.

Recommendation 5 The EA considers more effective ways to communicate and engage with farmers on high risk farms, to ensure that they are given appropriate information about their legal responsibilities to prevent pollution. Effectiveness of the message would be increased if it were also promoted by farming organisations such as the NFU and the Maize Growers’ Association.

5.4 Effectiveness of the project’s approach, and recommendations for follow-up The method employed by this project, incorporating independent land use advice coupled with a follow-up Environment Agency audit, has proved to be an effective model for delivering farm advice in specific targeted circumstances, and also in evaluating the scale of the maize issue. This model could effectively be replicated elsewhere. However, due to its short timescale and limited funding, the project has inevitably had some limitations:  The advice would have had most benefit during 2015 if it had been delivered significantly earlier in the season, as apart from harvesting early, some of the options for mitigation of pollution from the 2015 crop were understandably not possible and can only be implemented in 2016. The advisory cycle should start at the end of winter, looking at the fields after winter, assisting in planning which fields to grow maize in, planning for which fields need subsoiling , ensuring ‘very early’ varieties are selected, and drilling early if the soil is dry enough to maximise chances of an early harvest  More time is needed on each farm for advice and support; the approach in this project only provides a snap shot of the issues and identifies the breadth of risks and problems and the challenges in remedying. It is a challenge to encourage the farmer to give sufficient time to look in detail at the soil issues across the holding, however when joint visits with CBC and the EA were carried out, this was overcome in most cases  A one-year programme of work is inevitably limited in its scope, and the project farms would benefit from ongoing advice and support on maize growing from East Devon Catchment Partnership organisations and farming organisations. Positive relationships and trust between farmers and advisors take time to build.

Recommendation 6 Targeted follow up visits should be carried out in 2016 on all farms advised during the project. These visits should be fully evaluated. Workshops could also be organised to allow more in-depth discussion of the issues and options to avoid run-off.

6 Annexes to report

6.1 Land holdings in agri-environment schemes Table 6.1: Land holdings receiving advice that were in an agri-environment scheme

Farmer ID Catchment Sensitive Farming Entry Level Stewardship Scheme Farm 1

Farm 2 Y Y Farm 3 Y Y Farm 4 Y Y Farm 5

Farm 6 Y

Farm 7 Y

Farm 8 Y

Farm 9

Farm 10 Y

Farm 11 Y

Farm 12

Farm 13 Y

Farm 14

Farm 15

Farm 16 Y

Farm 17

Farm 18

Farm 19 Y Y Farm 20 Y

Farm 21 Y

Farm 22 Y

Farm 23

Farm 24 Y

Farm 25 Y

Farm 26 Y

Farm 27

Farm 28 Y Y Farm 29 Y

Farm 30

6.2 Breakdown of land holdings by catchment

Total hectarage of holdings visited in Clyst & Culm: 1084.89 ha Total hectarage of holdings visited in Sid & Otter: 992.93 ha Total hectarage of holdings visited in Lim & Axe: 1902.63 ha Total hectarage of holdings which didn’t fall into the project area: 518.89 ha

Number of holdings visited which fall within the Clyst & Culm: 7 Number of holdings visited which fall within the Sid & Otter: 10 Number of holdings visited which fall within the Lim & Axe: 19 Number of holdings visited which have some land which doesn’t fall within the project area: 4

Total hectarage of maize grown on holdings visited in Clyst & Culm: 182.94 ha Total hectarage of maize grown on holdings visited in Sid & Otter: 87.35 ha Total hectarage of maize grown on holdings visited in Lim & Axe: 399.32 ha Total hectarage of maize grown on holdings visited which doesn’t fall within project area: 45.68 ha

NB: Some holdings straddle one or more catchment. The table below is populated using the RLR field parcel as the smallest unit. Where an RLR field parcel straddles the boundary between two catchments it is assigned to the catchment in which the majority of that field parcel falls. Where an RLR field parcel straddles the boundary between a ‘project area’ catchment and ‘non-project area’ land, that parcel is assigned to the catchment.

Table 6.2 Breakdown of land holdings in the project by catchment

Area of maize Total area of farm Proportion of holding Operational Farms grown in visited which falls within which is in catchment Catchment visited catchment (ha) the catchment (ha) down to maize 2015 (%) 2015 Farm 7 55.21 7.38 13.37 Farm 10 165.06 15.61 9.46 Farm 11 229.20 35.65 15.55 Farm 16 138.16 36.37 26.32 Clyst & Culm Farm 22 52.02 0 0.00 Farm 26 303.58 21.87 7.20 Farm 29 141.66 66.07 46.64 TOTAL 1084.89 182.94 Farm 1 105.76 5.34 5.05 Farm 3 21.81 2.25 10.32 Sid & Otter Farm 7 79.98 18.68 23.36 Farm 11 149.40 0 0.00 36

Farm 14 157.80 0 0.00 Farm 17 45.61 6.31 13.83 Farm 22 58.85 14.02 23.82 Farm 24 268.73 27.71 10.31 Farm 26 15.83 0 0.00 Farm 27 89.16 13.05 14.64 TOTAL 992.93 87.35 Farm 1 47.43 11.98 25.26 Farm 2 102.68 37.72 36.74 Farm 3 127.29 10.72 8.42 Farm 4 47.85 12.92 27.00 Farm 5 226.62 18.82 8.30 Farm 6 101.48 12.63 12.45 Farm 8 61.51 4.44 7.22 Farm 9 43.94 21.91 49.86 Farm 12 162.74 39.86 24.49 Farm 13 144.19 17.78 7.84 Lim & Axe Farm 15 68.43 3.44 5.03 Farm 18 71.74 12.02 16.75 Farm 19 45.23 13.75 30.40 Farm 20 105.62 14.67 13.89 Farm 21 77.55 11.58 14.93 Farm 23 62.84 0 0.00 Farm 25 24.07 13.16 0.00 Farm 28 229.63 127.16 55.38 Farm 30 151.80 14.76 9.72 TOTAL 1902.63 399.32 Farm 2 52.50 11.80 22.48 Not falling within Farm 13 2.86 2.86 100.00 project area (some Farm 25 150.68 18.13 12.03 land within project area) Farm 26 312.84 0 0.00 TOTAL 518.89 45.68

6.3 Overview of soils by catchment Clyst and Culm catchment Winter wetness Percentage of maize grown in Clyst & Culm in 2015 on holdings visited on soils classified as ‘wet’ during winter: 12.01 % Percentage of maize grown in Clyst & Culm in 2015 on holdings visited on soils classified as ‘slightly wet’ during winter: 63.09 %

Percentage of maize grown in Clyst & Culm in 2015 on holdings visited on soils classified as ‘freely drained’ during winter: 24.90 % Table 6.3 Total hectarage of maize grown on project holdings in Clyst & Culm in 2015 Winter Wetness – Clyst and Culm Soil Association Freely drained Slightly wet Wet BRIDGNORTH 1.70 ha

BROCKHURST 1 17.71 ha

BROMSGROVE 23.62 ha

FLADBURY 1 4.26 ha

Newnham 20.24 ha

WHIMPLE 3 115.41 ha

TOTALS 45.56 ha 115.41 ha 21.97 ha

Run-off Risk Percentage of maize grown in Clyst & Culm in 2015 on holdings visited on soils classified with a ‘high’ run-off risk: 97.67 % Percentage of maize grown in Clyst & Culm in 2015 on holdings visited on soils classified with a ‘low’ run-off risk: 2.33 % Table 6.4 Total hectarage of maize grown on project holdings in Clyst & Culm in 2015 Run-off Risk – Clyst and Culm Soil Association High Low BRIDGNORTH 1.70 ha

BROCKHURST 1 17.71 ha

BROMSGROVE 23.62 ha

FLADBURY 1 4.26 ha

Newnham 20.24 ha

WHIMPLE 3 115.41 ha

TOTALS 178.68 ha 4.26 ha

Maize Harvesting Suitability Percentage of maize grown in Clyst & Culm in 2015 on holdings visited on soils classified as ‘not suitable’ for maize harvesting: 0.00 % Percentage of maize grown in Clyst & Culm in 2015 on holdings visited on soils classified as having a ‘low suitability’ for maize harvesting: 9.68 % Percentage of maize grown in Clyst & Culm in 2015 on holdings visited on soils classified as having a ‘moderate suitability’ for maize harvesting: 65.41 % Percentage of maize grown in Clyst & Culm in 2015 on holdings visited on soils classified as ‘suitable’ for maize harvesting: 24.90 %

Table 6.5 Total hectarage of maize grown on project holdings in Clyst & Culm in 2015 Maize Harvesting Suitability – Clyst and Culm Moderate Soil Association Not suitable Low suitability Suitable suitability BRIDGNORTH 1.70 ha

BROCKHURST 1 17.71 ha

BROMSGROVE 23.62 ha

FLADBURY 1 4.26 ha

Newnham 20.24 ha

WHIMPLE 3 115.41

TOTALS 0.00 ha 17.71 ha 119.67 ha 45.56 ha

Gulley Erosion Risk Percentage of maize grown in Clyst & Culm in 2015 on holdings visited on soils classified with a ‘risk of erosion on slopes’: 87.99 % Percentage of maize grown in Clyst & Culm in 2015 on holdings visited on soils classified as ‘low risk’ of gulley erosion: 12.01 % Table 6.6 Total hectarage of maize grown on project holdings in Clyst & Culm in 2015 Gulley Erosion Risk – Clyst and Culm Erosion on Soil Association Low risk slopes BRIDGNORTH 1.70 ha

BROCKHURST 1 17.71 ha

BROMSGROVE 23.62 ha

FLADBURY 1 4.26 ha

Newnham 20.24 ha

WHIMPLE 3 115.41 ha

TOTALS 160.97 ha 21.97 ha

Slurry Pollution Risk Percentage of maize grown in Clyst & Culm in 2015 on holdings visited on soils classified as having a ‘high’ slurry pollution risk: 72.77 % Percentage of maize grown in Clyst & Culm in 2015 on holdings visited on soils classified as having a ‘moderate’ slurry pollution risk: 2.33 % Percentage of maize grown in Clyst & Culm in 2015 on holdings visited on soils classified as having a ‘low’ slurry pollution risk: 24.90 %

Table 6.7 Total hectarage of maize grown on project holdings in Clyst & Culm in 2015 Slurry Pollution Risk – Clyst and Culm Soil Association High Moderate Low BRIDGNORTH 1.70 ha

BROCKHURST 1 17.71 ha

BROMSGROVE 23.62 ha

FLADBURY 1 4.26 ha

Newnham 20.24 ha

WHIMPLE 3 115.41 ha

TOTALS 133.12 ha 4.26 ha 45.56 ha

Lim and Axe Catchments Winter wetness Percentage of maize grown in Lim & Axe in 2015 on holdings visited on soils classified as ‘wet’ during winter: 23.26 % Percentage of maize grown in Lim & Axe in 2015 on holdings visited on soils classified as ‘slightly wet’ during winter: 59.56 % Percentage of maize grown in Lim & Axe in 2015 on holdings visited on soils classified as ‘freely drained’ during winter: 17.18 % Table 6.8 Total hectarage of maize grown on project holdings in Lim & Axe in 2015 Winter Wetness – Lim & Axe Soil Association freely drained slightly wet wet BATCOMBE 142.08 ha BEARSTED 2 38.01 ha CHARITY 1 30.61 ha DENCHWORTH 5.28 ha DUNKESWELL 28.44 ha FLADBURY 1 14.56 ha HENSE 25.85 ha WHIMPLE 3 95.75 ha WICKHAM 2 13.89 ha WORCESTER 4.85 ha TOTALS 68.62 ha 237.83 ha 92.87 ha

Run-off Risk Percentage of maize grown in Lim & Axe in 2015 on holdings visited on soils classified with a ‘high’ run-off risk: 89.88 % Percentage of maize grown in Lim & Axe in 2015 on holdings visited on soils classified with a ‘low’ run-off risk: 10.12 %

Table 6.9 Total hectarage of maize grown on project holdings in Lim & Axe in 2015 Run-off Risk – Lim & Axe Soil Association High Low BATCOMBE 142.08 ha BEARSTED 2 38.01 ha CHARITY 1 30.61 ha DENCHWORTH 5.28 ha DUNKESWELL 28.44 ha FLADBURY 1 14.56 ha HENSE 25.85 ha WHIMPLE 3 95.75 ha WICKHAM 2 13.89 ha WORCESTER 4.85 ha TOTALS 358.91 ha 40.41 ha

Maize Harvesting Suitability Percentage of maize grown in Lim & Axe in 2015 on holdings visited on soils classified as ‘not suitable’ for maize harvesting: 6.47 % Percentage of maize grown in Lim & Axe in 2015 on holdings visited on soils classified as having a ‘low suitability’ for maize harvesting: 13.14 % Percentage of maize grown in Lim & Axe in 2015 on holdings visited on soils classified as having a ‘moderate suitability’ for maize harvesting: 63.21 % Percentage of maize grown in Lim & Axe in 2015 on holdings visited on soils classified as ‘suitable’ for maize harvesting: 17.18 % Table 6.10 Total hectarage of maize grown on project holdings in Lim & Axe in 2015 Maize Harvesting Suitability – Lim & Axe Moderate Soil Association Not suitable Low suitability Suitable suitability BATCOMBE 142.08 ha BEARSTED 2 38.01 ha CHARITY 1 30.61 ha DENCHWORTH 5.28 ha DUNKESWELL 28.44 ha FLADBURY 1 14.56 ha HENSE 25.85 ha WHIMPLE 3 95.75 ha WICKHAM 2 13.89 ha WORCESTER 4.85 ha TOTALS 25.85 ha 52.46 ha 252.39 ha 68.62 ha

Gulley Erosion Risk Percentage of maize grown in Lim & Axe in 2015 on holdings visited on soils classified with a ‘risk of erosion on slopes’: 41.16 % Percentage of maize grown in Lim & Axe in 2015 on holdings visited on soils classified as ‘low risk’ of gulley erosion: 58.84 % Table 6.11 Total hectarage of maize grown on project holdings in Lim & Axe in 2015 Gulley Erosion Risk – Lim & Axe Erosion on Soil Association Low risk slopes BATCOMBE 142.08 ha BEARSTED 2 38.01 ha CHARITY 1 30.61 ha DENCHWORTH 5.28 ha DUNKESWELL 28.44 ha FLADBURY 1 14.56 ha HENSE 25.85 ha WHIMPLE 3 95.75 ha WICKHAM 2 13.89 ha WORCESTER 4.85 ha TOTALS 164.38 ha 234.95 ha Slurry Pollution Risk Percentage of maize grown in Lim & Axe in 2015 on holdings visited on soils classified as having a ‘high’ slurry pollution risk: 36.47 % Percentage of maize grown in Lim & Axe in 2015 on holdings visited on soils classified as having a ‘moderate’ slurry pollution risk: 3.65 % Percentage of maize grown in Lim & Axe in 2015 on holdings visited on soils classified as having a ‘low’ slurry pollution risk: 59.89 % Table 6.12 Total hectarage of maize grown on project holdings in Lim & Axe in 2015 Slurry Pollution Risk – Lim & Axe Soil Association High Moderate Low BATCOMBE 142.08 ha

BEARSTED 2 38.01 ha

CHARITY 1 30.61 ha

DENCHWORTH 5.28 ha

DUNKESWELL 28.44 ha

FLADBURY 1 14.56 ha

HENSE 25.85 ha

WHIMPLE 3 95.75 ha

WICKHAM 2 13.89 ha

WORCESTER 4.85 ha

TOTALS 145.62 ha 14.56 ha 239.14 ha

Sid and Otter Catchments Winter wetness Percentage of maize grown in Sid & Otter in 2015 on holdings visited on soils classified as ‘wet’ during winter: 22.45 % Percentage of maize grown in Sid & Otter in 2015 on holdings visited on soils classified as ‘slightly wet’ during winter: 66.23 % Percentage of maize grown in Sid & Otter in 2015 on holdings visited on soils classified as ‘freely drained’ during winter: 11.32 % Table 6.13 Total hectarage of maize grown on project holdings in Sid & Otter in 2015 Winter Wetness – Sid & Otter Soil Association freely drained slightly wet wet BEARSTED 2 4.34 ha BROCKHURST 1 5.66 ha BROMSGROVE 5.55 ha CONWAY 0.20 ha WHIMPLE 3 57.85 ha WORCESTER 13.75 ha TOTALS 9.89 ha 57.85 ha 19.61 ha

Run-off Risk Percentage of maize grown in Sid & Otter in 2015 on holdings visited on soils classified with a ‘high’ run-off risk: 99.77 % Percentage of maize grown in Sid & Otter in 2015 on holdings visited on soils classified with a ‘low’ run-off risk: 0.23 % Total hectarage of maize grown on project holdings in Sid & Otter in 2015 Run-off Risk – Sid & Otter Soil Association High Low BEARSTED 2 4.34 ha BROCKHURST 1 5.66 ha BROMSGROVE 5.55 ha CONWAY 0.20 ha WHIMPLE 3 57.85 ha WORCESTER 13.75 ha TOTALS 87.15 ha 0.20 ha

Maize Harvesting Suitability Percentage of maize grown in Sid & Otter in 2015 on holdings visited on soils classified as ‘not suitable’ for maize harvesting: 0.00 % Percentage of maize grown in Sid & Otter in 2015 on holdings visited on soils classified as having a ‘low suitability’ for maize harvesting: 22.22 % Percentage of maize grown in Sid & Otter in 2015 on holdings visited on soils classified as having a ‘moderate suitability’ for maize harvesting: 66.46 % 43

Percentage of maize grown in Sid & Otter in 2015 on holdings visited on soils classified as ‘suitable’ for maize harvesting: 11.32 % Table 6.14 Total hectarage of maize grown on project holdings in Sid & Otter in 2015 Maize Harvesting Suitability – Sid & Otter Moderate Soil Association Not suitable Low suitability Suitable suitability BEARSTED 2 4.34 ha BROCKHURST 1 5.66 ha BROMSGROVE 5.55 ha CONWAY 0.20 ha WHIMPLE 3 57.85 ha WORCESTER 13.75 ha TOTALS 19.41 ha 58.06 ha 9.89 ha

Gulley Erosion Risk Percentage of maize grown in Sid & Otter in 2015 on holdings visited on soils classified with a ‘risk of erosion on slopes’: 77.55 % Percentage of maize grown in Sid & Otter in 2015 on holdings visited on soils classified as ‘low risk’ of gulley erosion: 22.45 % Table 6.15 Total hectarage of maize grown on project holdings in Sid & Otter in 2015 Gulley Erosion Risk – Sid & Otter Erosion on Soil Association Low risk slopes BEARSTED 2 4.34 ha

BROCKHURST 1 5.66 ha

BROMSGROVE 5.55 ha

CONWAY 0.20 ha

WHIMPLE 3 57.85 ha

WORCESTER 13.75 ha

TOTALS 67.74 ha 19.61 ha

Slurry Pollution Risk Percentage of maize grown in Sid & Otter in 2015 on holdings visited on soils classified as having a ‘high’ slurry pollution risk: 88.45 % Percentage of maize grown in Sid & Otter in 2015 on holdings visited on soils classified as having a ‘moderate’ slurry pollution risk: 0.23 % Percentage of maize grown in Sid & Otter in 2015 on holdings visited on soils classified as having a ‘low’ slurry pollution risk: 11.32 %

Table 6.15 Total hectarage of maize grown on project holdings in Sid & Otter in 2015 Slurry Pollution Risk Soil Association High Moderate Low BEARSTED 2 4.34 ha

BROCKHURST 1 5.66 ha

BROMSGROVE 5.55 ha

CONWAY 0.20 ha

WHIMPLE 3 57.85 ha

WORCESTER 13.75 ha

TOTALS 77.26 ha 0.20 ha 9.89 ha

6.4 Mapping of land holdings influenced

Mapping of the land holdings influenced.

6.5 Example letters to landowners

ADDRESS

DATE

Dear Landowner,

Campaign to reduce risk of pollution and flooding from maize

I am writing to offer you a free advisory visit to discuss maize management to reduce runoff.

As a farmer in East Devon, you will be aware of the work undertaken over the past twenty years to improve the water quality. Despite substantial work, there still remains a problem with waters not meeting their targets. Runoff from maize remains a serious pollution concern. Many farmers may not be aware of their legal obligations to prevent this type of pollution, and that they may be at risk of causing an offence.

The East Devon Catchment Partnership, a partnership of government and non government organisations, which includes the Environment Agency, Devon Wildlife Trust, Natural England and the Westcountry Rivers Trust, has developed a project to focus more effort on maize. The project aims to provide further advice on ways to reduce runoff and the new rules associated with soil management. The project is focusing on farms that grow maize in East Devon.

To support the project, Chantal Brown Consulting (CBC) has been contracted to carry out farm visits to provide free advice.

Our farm advice visits will be an opportunity for you to:  Discuss the runoff risks associated with maize growing  Understand the water quality problem with latest facts and figures  Be signposted to grant aid to support your farm business  Clarify the new GAECs under cross-compliance relating to soil, which came into play January 2015  Gain a clear understanding of the EA regulatory process and implications.  Identify cost savings on your farm by looking at soil issues and management on a field by field basis with advisors with agronomy experts

If you would like a free, independent advisory visit, please call Louise (CBC) on 07951 353 292. Initial visits can be arranged at a date and time to suit you during August/September.

Following on from this the Environment Agency will be carrying out visits assessing soil runoff and pollution from maize within the entire East Devon Catchment, between January and mid-March 2016. Causing pollution via soils run off is an offence and significant pollution is found the Environment Agency may take enforcement action.

If you would like to discuss the project in more detail, please call me on 07778 700539.

Yours faithfully,

Chantal Brown Independent Farm Advisor

On behalf of East Devon Catchment Partnership xxth December 2015

Dear xxx,

Thank you for inviting me to the farm on xxxx. I have attached the letter from your previous visit for reference. Please also find attached the soil maps for your holding with the key attached, and the LIDAR maps that show run-off pathways across the holding. The LIDAR maps were generated by the EA using data from their aerial survey using laser technology when a plane flew the area and captured the detailed topography. The potential runoff pathways were then plotted based on the lie of the land. They have not been ground-truthed so should be treated as a guide only.

Field overview: In 2015 maize was grown in the fields marked 7418 and 0713. I also looked at the field going into maize next year which is 2984. The two fields out of maize had been turned back to grass, and the field for 2016 is grass at the moment. The maize was cut on 8th October, which given that most maize was late maturing this year was pretty good. I have given each of the fields a risk score based on size, slope, compaction, soil type and location. This can be seen in the table later in this report. 7418 – This field is inherently high risk. Though it is a small field it has a steepish slope towards a road, so there is the potential to cause diffuse pollution issues if managed poorly or during heavy rain events.

The maize had been drilled at the end of April, and harvested on 8th October. This is only slightly later than the farms average end Sept harvest. The conditions were dry at harvest and as such compaction was not too bad. After harvest the field had been cultivated with a sumo, which had removed what compaction there was, as can be seen below.

Grass seed was broadcast and the field was then flat rolled. The grass was emerged and at 1-2lf. The flat roll had left the field with a flat surface. Before and during my visit we had a lot of heavy rain, which was sitting on top of the soil, and running down the slope and gathering at the bottom of the field. My advice would have been to not flat roll the field, and instead use Cambridge rolls, or better still not roll at all. It was evident in a small area that had been missed with the rolls the soil was coping with the rainfall.

Water sitting on surface of flat rolled areas

Area missed with rolls absorbing rainfall well

0713 – This field is also inherently high risk of diffuse pollution. It is a fairly big field with a steepish slope that starts to flatten out at the bottom. The field slopes to a stream which runs across the field gateway.

The management of this field had been similar to the field already mentioned. It had been harvest on 8th October, sumo’d, but then power harrow drilled and flat rolled. The soil condition was also very similar to the previous field, with no serious compaction below ground, but the flat rolling and then heavy rain had left a very smooth soil surface which was not allowing rainfall to be absorbed. Due to the size of the field providing a large catchment area, a lot of water was making its way down the hill and out of the gateway.

I again think this could have been avoided by not using the flat roller.

7669 – This field also carries with it a fairly high inherent risk. It is sloping towards the gateway in the bottom corner which leads to a road. The road crosses the Corry Brook about 70 metres from the field gateway.

The field is currently in grass, and will be going to maize in Spring 2016. The grass condition was very good, yet due to the level of rain we were having, and due to the large catchment area of the field there was water leaving the field through the gateway. This field will need careful management next autumn once the maize is cut.

Field advice: 7418 & 0713 – Ideally this field would not have been flat rolled. If the maize had been cut in September, and the grass planted within a few days, then flat rolling is still an option, but I would advise that once we get into October and the risk of prolonged rainfall increases, the flat roll be abandoned and either don’t roll or Cambridge roll. It’s a difficult decision as at the time of drilling the weather was very dry and moisture preservation to aid establishment would have been an issue, but I think you have to take into account the inherent risk, which in these fields is high. What the fields have going for them is that when I walked them at the beginning of November the grass was well established, and after another 6 weeks of growing conditions it will have moved on, and should provide good cover over winter. 2984 – Due to the high inherent risk associated with this field, all measures to ensure an early harvest should be taken. I also recommend leaving the field corner around the gateway down to grass. This will provide a buffer should we experience adverse conditions next autumn. It is very important to consider the risk of a field when planning which fields to grow maize in. I highly recommend giving all available fields a risk score and then look to select those with the lowest scores in which to grow maize. Should it be necessary to crop high risk fields with maize, then the following advice should be followed: Always select early maturing varieties, ideally Maturity Group 10. Do not delay drilling when conditions are suitable. Waiting for a last cut of silage from a grass field before drilling maize in June will ALWAYS result is a delayed harvest. Consider drilling under plastic. I appreciate there is a large cost associated with this, but the benefits will include an earlier harvest and potentially improved yield and quality. Aim to harvest the maize as soon as mature, and in dry conditions. After harvest if wheat is planned then remove compaction and drill as soon as possible. If possible do not roll fields, especially if harvest and drilling has been delayed. Drill across tramlines wherever possible. Aim not to traffic tramlines until the spring. Always have a contingency plan for ‘bad’ years. There will be times when harvest is too late, or conditions too wet to establish a following crop. An example of an alternative plan would be to roughly cultivate fields across slopes to break run-off pathways, and look to drill a spring crop instead of a winter one. Consider ‘permanent’ measures in high risk fields, such as buffer strips alongside water courses. As stated in my initial letter (July 2015), the Environment Agency will be doing a catchment walk over between January and March 2016. Unfortunately, this season was wet and cold and as such all farmers I have visited harvested their maize later than planned, and certainly much later than ideal. However, if there is a serious run-off problem, a cold August is not sufficient justification for polluting a water course or contributing to flooding. In the part of East Devon where you farm, where there is typically substantial rain-fall, increasing heavy rainfall and random weather events throughout the year, it is highly unlikely that on any given year, any farmer in East Devon will have ideal drilling conditions, a stable growing season and ideal harvest conditions for maize. It is necessary to plan for the weather that we are likely to get, rather than the weather we hope to get, and take into serious consideration, the soil type, condition, slope and environmental features surrounding each field. It is with this in mind, I have, as an example, looked at the risk of the fields we visited in the below table.

Total RLR Parcel Risk Risk Soil Risk Environmental Risk Risk parcel Slope Compaction Risk size (1-5) (1-5) type (1-5) Features (1-5) of no. field 7418 – grass after Sml- Mod- Surface maize mod 3 high 5 Medium 4 Road at bottom 4 capped 4 20/25 0713 – grass after Stream at Surface maize Large 5 Mod 4 Medium 4 bottom 5 capped 4 22/25 2984 Road at bottom, – Mod- Corry Brook grass Mod 4 high 4 Medium 4 down road 5 Low 2 19/25

I appreciate maize is a valuable feed source for your cows and an important crop to sustain your farm business through this period of growth and hardships with milk prices among other challenges. Please consider the actual risk to your business if serious run-off is identified and put all the measures in place to ensure the crop is harvested as early as possible and only low risk fields are chosen for maize growing, so particularly bad weather doesn’t catch you out and result in a scenario that is not wanted by anyone. It is likely that run-off from maize and following crops will continue to be closely looked at in years to come, due to the extent of the issue and its actual and potential impact. Thank you for engaging so positively with this project and please feel free to contact myself or Rob Lamboll, your Catchment Sensitive Farming (CSF) Officer if you have further queries relating to soil and run-off. There are a number of free advisory visits available under the CSF scheme that may be of use to you and would support any future grant applications. Please can I take the opportunity to encourage you to invest the time and money in planning your maize growing even more carefully in the future. With the risks maize can cause to water quality, flooding and roads, it is an issue that is now being very closely looked at by a number of organisations, including regulatory bodies such as the RPA and the Environment Agency. The decisions you make throughout the year will determine the outcome from any regulatory visits from the RPA or the EA and the condition of your land remains your responsibility. Feel free to contact me with any questions, corrections or comments: xxx. Let me know if you need any of the attachments re-sent from my previous correspondence. Many Thanks, xxx On behalf of East Devon Catchment Partnership

6.6 Factsheets developed for the project

These are attached to this report. They comprise 10 fact sheets for landowners as follows:

1 The water quality problem in east Devon 2 Soil runoff and water pollution legislation 3 Serious water pollution from soil erosion 4 Cross compliance – controlling soil erosion 5 Pollution from manures and slurries on maize 6 Soil types and risk of runoff in east Devon 7 Causes of soil runoff in east Devon 8 Research measuring runoff from maize stubble 9 Preventing soil runoff in east Devon 10 Summary of best practice to prevent soil runoff

The factsheets were written by Richard Smith, soils specialist from EA, with input from other East Devon Catchment Partnership members. They were printed and provided to all landowners visited in the project, and also taken to the workshops and events attended.

6.7 Project budget

Costs (£)

Project management and reporting 8,163 Postage and materials 649.70 Travel 2,574 Professional fees (consultancy) 28,290

Others, please specify: contingency @ 10% Total 39,4121676.70